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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA Criminal Action No. 08Plaintiff, v. WHITNEY ANN WILSON, Defendant.
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INDICTMENT
The Grand Jury for the District of Delaware charges that:
COUNT I
1. From in or around December 2007, through in or around February 2008,
\VHITNEY ANN \VILSON, defendant herein, stole, anel took, from or uut of a lettc;r box, mail receptacle, and other authorized depository for mail matter, a letter, postal card, package, bag, and mail, and, unlawfully had in her possession, any letter, postal card, package, bag, or mail, which had been stolen and taken, knowing the same to have been stolen and taken, all in violation of Title 18 United States Code Section 1708.
COUNTS II THROUGH XXII Scheme and Artifice to Defraud
2. At all times relevant to this Indictment, Wilmington Trust and Wilmington
Savings Fund Society, FSB ("WSFS") were federally insured financial institutions, the deposits of which were insured by the Federal Deposit Insurance Corporation (or "FDIC"). 3. From in or around December 2007, through in or around February 2008,
WHITNEY AJ\!l\l" WILSON, defendant herein, devised a scheme and artifice to defraud
Case 1:08-cr-00067-SLR
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Wilmington Trust and WSFS, which are federally insured financial institutions, and to obtain funds owned by or under the custody or control of Wilmington Trust and WSFS, by means of false and fraudulent pretenses, representations, and promises. 4. As part of the scheme and artifice to defraud, the defendant stole outgoing mail
that other persons (the "account holders") placed in their curbside, resident mailboxes, in an effort to obtain personal checks that the account holders had drafte d to pay their bills. 5. As a further part of the scheme and artifice to defraud, when the defendant found
a personal check drawn on an account with WSFS or Wilmington Trust in a piece of stolen mail, the defendant would enter the information from the account holder's check, including the account holder's name, address, and account number, and the bank's routing number, into a computer, and use software to create a fraudulent blank personal check with the account holder's identifying infol1nation. 6. As a further part ofthe scheme and aliifice to defraud, the defendant would draft
the fraudulent checks as payable to one of several persons to whom the defendant provided the fraudulent checks to cash (the "check cashers"), and endorse the fraudulent checks by forging the account holders' signatures. 7. As a further parL of the scheme and artifice to defl-aud, the defendanL and a check
casher would take the fraudulent checks to a WSFS or Wilmington Trust branch in New Castle County, Delaware. The check casher would cash the fraudulent checks and return a portion of the cash proceeds to the defendant.
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Charging Paragraph
COUNTS II - IX
8.
From in or around December 2007, through in or around February 2008, in the
State and District of Delaware, WHITNEY ANN WILSON, defendant herein, did knowingly execute, and attempt to execute, a scheme and artifIce to defraud and obtain funds owned by or under the custody or control ofWSFS, a federally insured financial institution, by means of false and fraudulent pretenses, representations, and promises, which scheme or artifIce is described more fully in paragraphs 2 - 7 above, incorporated herein by reference, and in execution of the scheme or artifIce, with-the intent to defraud WSFS, cashed and attempted to cash the fraudulei1t checks identifIed by account and check numbers in the table below, in the names of the persons identified in the table below, all in violation of Title 18, United States Code, Sections 1344 and
Count
Account Holder's Initials
Account Number
Date
Check Number(s)
Count II Count III Count IV Count V Count VI
A.B. J.e. N.H. A.B. e.R.
xxx-xxx-747 xxx-xxx-0 12 xxx-xxx-676 xxx-xxx-O 16 xxx-xxx-510
December 5, 2007 December 20,2007 December 28,2007 January 8, 2008 January 8, 2008
1545, 1548 849,850, 851 2203 9198,9200 1176,1177, 1178, 1179, 1180, 1181 1015,1017 927
Count VII Count VIII
R.V. R.K.
xxx-xxx-533 xxx-xxx-461
December 12, 2007 January 12,2008
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Count IX
lB.
xxx-xxx-766
January 15,2008
8397,8398, 8401
COUNTS X-XXII 9. From in or around December 2007, through in or around February 2008, in the
State and District of Delaware, WHITNEY ANN WILSON, defendant herein, did knowingly execute, and attempt to execute, a scheme and artifice to defraud and obtain funds owned by or under the custody or control of Wilmington Trust, a federally insured financial institution, by means offalse and fraudulent pretenses, representations, and promises, which scheme or artifice is described more fully in paragraphs 2 - 7 above, incorporated herein by reference, and in execution of the scheme or artifice, with the intent to defraud Wilmington Trust, cashed and attempted to cash the fraudulent checks identified by account and check numbers in the table below. in the names of the persons identified in the table below. all in violation of Title 18. United States Code, Sections 1344 and 2. Count Account Holder's Initials A.S. J.P. K.H. L.W. S.R. B.F. M.W. Account Number Date Check Number(s) 1638,1641, 1645 5585,5587 3772,3773, 3774,3775 1484 1693,1694 2797,2798, 2799 1539, 1541
Count X Count XI Count XII Count XIII Count XIV Count XV Count XVI
xxxxx-275 xxxxx-370 xxxxx-331 xxxxx-583 xxxxx-Cf'27 xxxxx-283 xxxxx-632
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December 5, 2007 December 14,2007 December 18, 2007 December 28, 2007 January 3, 2008 January 4,2008 January 5, 2008
.......
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Count XVII Count XVIII Count XIX Count XX
V.H. R.W. J.T. K.L. D.O. H.V.
xxxxx-539 xxxxx-OOO xxxxx-822 xxxxx-546 xxxxx-708 xxxxx-099 COUNT XXIII
January 11,2008 January 11,2008 January 14,2008 January 14 & 15, 2008 January 15,2008 January 17,2008
3420,3424 2358,2360 3512,3514, 3515,3516 3445,3447 3262 5084
Count XXI Count XXII
10.
From in or around December 2007, through in or around February 2008, in the
State and District of Delaware, WHITNEY ANN WILSON, defendant herein, did knowingly use, without lawful authority, the means of identification of J.B., to wit, J.B.'s name, and in conjunction therewith . .l.B. 's :Iddress :Ind h:Ink account number. dming and in rebtion to the violation of Title 18, United States Code, Sections 1344 and 2 described in Count IX above, all in violation of Title 18, United States Code, Sections 1028A and 2. COUNT XXIV 11. From in or around December 2007, through in or around February 2008, in the
State and District of Delaware, WHITNEY ANN WILSON, defendant herein, did knowingly use, without lawful authority, the means of identification ofD.G., to wit, D.G.'s name, and in conjunction therewith, D.O.'s address and bank account number, dming and in relation to the violation of Title 18, United States Code, Sections 1344 and 2 described in Count XXI above, all in violation of Title 18, United States Code, Sections 1028A and 2. COUNT XXV 12. From in or around December 2007, through in or around February 2008, in the
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State and District of Delaware, WHITNEY ANN WILSON, defendant herein, did knowingly use, without lawful authority, the means of identification ofR.V., to wit, R.V.'s name, and in conjunction therewith, R.V. 's address and bank account number, during and in relation to the violation of Title 18, United States Code, Sections 1344 and 2 described in Count VII above, all in violation of Title 18, United States Code, Sections 1028A and 2.
A TRUE BILL:
/
Foreperson COLM F. CONNOLLY
United St:ltes /\ ttomey
BY:
~v~/ 0
Seth M. 13eausang Assistant United States Attomey
Dated: April 22, 2008
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